Summary of ANSI Z359 Fall Protection Guidelines
The new ANSI Z359 standards for fall protection include several updated policy recommendations that deviate from many of the previously established OSHA policies. After carefully reviewing the newly established ANSI standards, OSHA has their existing Regulations and Compliance Directives under review. OSHA is expected to issue their newly revised Regulatory Standards.
Caution must be exercised when discussing the proposed regulatory changes that will be introduced by OSHA with those unfamiliar with ANSI Standards. To properly comprehend the responsibility of ANSI, we must first understand what ANSI is and what is defined in their charter. ANSI stands for “American National Standards Institute”. Standards writing committees are chartered by ANSI to develop certain standard practices and procedures for American Industry. When ANSI agrees to produce a National Consensus Policy, it typically issues a public invitation to form a committee consisting of several members of affected interest. Those members typically consist of representatives from those specific industries which may be affected by the standards they shall develop and author. Committee members generally are recruited from general industry, government (e.g. representatives from OSHA), labor unions, liability insurance carriers, and legal advisors. The Independent Committee, once approved by ANSI, is chartered to develop and author a specific set of practical policy guidelines for the engineering, manufacture, testing, and usage procedures of the products in question.
ANSI does not regulate or enforce any laws or regulations. ANSI merely recommends policies to general industry as well as governmental regulatory agencies. ANSI policies are commonly known as Consensus Policies, although the committee’s members do not have to be in unanimous agreement. A consensus agreement of a substantial majority is the only requirement to reach a recommendation. Once an ANSI committee issues it’s recommendations, ANSI must review the recommendation prior to issuing its standard. The ramifications of implementation of the standards issued by ANSI are typically weighed by those industries and governmental regulatory agencies which are affected by the standards. With regard to ANSI standards involving significant safety issues, new laws are typically written soon after the introduction of revised ANSI Standards.
Let’s discuss the role of ANSI with regard to OSHA. OSHA employees obviously have a significantly challenging mandate. OSHA is the governmental agency responsible for making the American Industrial Workplace safe from accidental injuries and death for its workforce. Since it would be virtually impossible for OSHA employees to know everything they must know about fall protection issues for all the various industries they service, OSHA Regulatory Standards Writers must solicit help from knowledgeable people from those industries affected by their policies. ANSI fills that role very capably.
The ANSI Z359 Standard was approved on May 31, 2007. It is published in four components, as follows:
Z359.1 “Safety Requirements for Personal Fall Arrest Systems, Subsystems and Components”.
Z359.2 “Minimal Requirements for a Comprehensive Managed Fall Protection Program”.
Z359.3 “Safety Requirements for Positioning and Travel Restraint Systems”.
Z359.4 “Safety Requirements for Assisted-Rescue and Self-Rescue Systems, Subsystems and Components”.
Each of the four subcategories recommends standards policies that OSHA is reviewing for possible inclusion in its new regulatory standard for fall protection. While OSHA is not bound by any laws or established protocol for adoption or incorporation, the recommendations of the ANSI Z359 Standards Committee certainly carry immense weight with the OSHA Standards Authors. Most if not all of the recommendations are expected to become OSHA Regulations. OSHA has already completed most of their process of review and consideration for adoption, and is now in the final stages of revision of its own fall protection policy, however the specific recommendations which will be adopted and included in OSHA policy are not yet available to the public. The proposed changes that will be incorporated have been drafted, and they have been widely circulated internally on a strict confidential basis among OSHA employees for agency review and comments. Once their internal review is completed, the proposed standards will be printed in the Federal Register with a Public Call for Comments. The current projected date of release of the preliminary text is April 2008. OSHA will allow a short period of time to receive public comments and review them, and will probably make some minor revisions prior to formal introduction of the final policy in mid-year 2008.
Here is a summary of our opinion of the major changes we may expect:
Z359 is expected to mandate a giant step forward from existing OSHA policy. Current OSHA policy has traditionally allowed certain specific industries (like the Construction Industry) to determine their own needs for fall protection. OSHA has always allowed a few industries to establish National Consensus Standards for their particular industries, however the potential expansion of that policy has been criticized by many safety professionals who have publicly decried the practice, claiming that OSHA should not expand on that practice by allowing the proverbial “mouse to design the mousetrap”. With the new proposed regulations, a uniform policy for fall protection is anticipated for general industry with fewer exceptions. The Construction Industry and The Sports Industry (e.g. Mountaineering, Track and Field, etc.) are expected to be allowed to continue to set their own standards, where and when applicable, since they were specifically excluded from the recommendations of ANSI Z359.
Walking/working surfaces atop trains, trailers, rooftops and many other applications which were not necessarily considered OSHA violations in the past are widely expected to be incorporated into the new fall protection policies, eliminating many of the loopholes that have been accepted practices for certain industries in the past.
When we consider the overwhelming cost of the fall protection equipment that would be required to deliver 100% fall protection coverage over certain vast areas, such as trying to cover a 110 car long grain industry train which extends well over a mile in length, the grain industry’s argument seems incredibly valid. But this is an example in which a reasonably effective compromise can be reached. When you take a moment to consider the alternatives to full length coverage, it really isn’t quite that cost prohibitive. Several major grain handling companies, for example, have already begun to address this issue by introducing policies that restrict people from climbing and walking on top of a long train of rail cars except where a more limited span of coverage may be affordably provided. Revised handling procedures will likely have to be introduced as well, but the compromise solution seems more practical and acceptable when it includes requiring those personnel accessing long trains to limit their travel to more limited but affordably protected areas.
A written rescue/retrieval policy must be provided to all employees who use a fall protection system. Within the previous OSHA policy, it was a requirement to establish a policy although it was not required to establish that policy in writing.
Certain mandatory requirements for the design and manufacture of fall protection equipment have been established by ANSI to regulate the fall arrest equipment manufacturers. Several American companies have produced fall arrest systems that simply do not meet minimal ANSI standards for acceptable design, testing and installation. Minimal engineering and labeling criteria standards have now been established, although it remains to be seen how OSHA will regulate and enforce the recommendations of the ANSI Standards. The larger manufacturers have typically conscientiously forced themselves to meet rigid design, manufacturing and testing standards, yet there are manufacturers who have successfully avoided any type of controls for years. Fall protection equipment manufacturers are watching OSHA closely to see if those systems that are built from cheap, substandard and virtually ineffective equipment will be removed from the market with the introduction of the new standards. With the new ANSI standards being clearly defined for compliant manufacturers, OSHA has an opportunity to establish certain basic manufacturing and testing procedures which should eliminate the installation of substandard equipment from the fall protection industry.
General Instructions in English will have to be provided by the equipment manufacturers for fall protection components and systems and shall be affixed to the equipment prior to shipment. Those instructions must include, among other data, name and address and telephone number of manufacturer, parts identification numbers, model identification, inspection procedures, anchorage requirements, criteria for proper methods for using the equipment, criteria for discarding equipment which fails inspection, procedures for cleaning, maintenance and storage, limits on the use of the equipment, and reference to the ANSI/ASSE Z359.1 and ANSI Z359.4 standards and applicable regulations governing safe rescue operations. Instructions stating that only the equipment manufacturer, or other persons authorized in writing by the manufacturer, shall make repairs to the equipment. Instructions must state that the rescuer must remove the equipment used for a fall arrest from service until repair or replacement has been completed by the manufacturer. Instructions must be included to the user that a rescue and retrieval plan must be in effect and the means of rescue must be at hand prior to usage of the equipment.
A competent person must inspect the fall protection equipment no less than annually. Documentation on annual inspections must be kept by the rescuers organization, which shall consist of no less than the identity of the equipment, inspection date, name of the competent person conducting the inspection, and the results of that inspection.
Training on harness suspension issues is required. Suspension trauma is the dangerous condition caused by poor blood circulation typically caused by an extended period of suspension in a harness. Fall victims are to be instructed to move their legs and try to push against a safe foothold, and fall victims should also try to raise their legs up as far and as often as possible toward a sitting position to facilitate circulation. Rescuers of fall arrest victims must be properly trained to address the issues of suspension trauma. New guidelines suggest keeping the victim in an upright position for 30 minutes, after which he is moved slowly and carefully to a kneeling position, then sitting, and finally to a prone position, after which the victim should be seen by a physician. This is done to avoid the sudden rush of blood to vital organs when a victim is removed from suspension. Rescuers should maintain documentary proof of their training procedures and their training sessions.
ANSI Z359.2 establishes the Minimum Requirements for a Comprehensive Managed Fall Protection Program. This standard is not expected to become a mandatory requirement by OSHA. It lays out the practical guidelines to be followed in establishing a corporate managed fall protection program and provides definitions of the various participants with specific titles and functions.
